Health insurance contributions on reimbursement of travel expenses for board members appointed by resolution
Reimbursement of travel expenses for board members is, as a rule, exempt from income tax (PIT) and social security contributions.
Transfer pricing adjustments and VAT – The Arcomet Case
As part of our series TP and VAT, where we discuss key issues concerning intra-group transactions (Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT | MDDP), we covered the Arcomet case (C-726/23) and the opinion of the Advocate General of the CJEU (A new perspective from the…
Application of Guidelines to payments to investment funds
The tax Guidelines published by the Ministry of Finance concerning the application of the so-called beneficial owner clause for withholding tax purposes (hereinafter: Guidelines) are intended to clarify the rules for applying this clause in the context of the withholding tax collection obligation. One of the issues that has raised doubts in the past was…
Excise duty on alcohol used in biocidal products – judgment and implications for the industry
The Voivodship Administrative Court in Gliwice, in a non-final judgment (ref. III SA/Gl 895/24), upheld the position of the tax authorities and ruled that disinfectant liquid is subject to excise duty. Why is excise duty on biocidal alcohol controversial? Recently, excise duty on alcohol used in biocidal products has become a subject of dispute between…
Simple joint-stock company and income tax – what do you need to know?
Since 2021, it has been possible to conduct business activity in the form of a simple joint-stock company (PSA). The PSA was intended to address the challenges of the modern economy – no barriers to entry, simplified profit distribution and faster liquidation, in short – the ideal legal form for start-ups. However, entrepreneurs still approach…
Estonian CIT versus the decision on support in the Polish Investment Zone – the latest interpretation by the Director of the National Tax Information Service and its significance for entrepreneurs
For many entrepreneurs, Estonian CIT means an opportunity for simplified settlements and greater financial liquidity, but at the same time – a number of conditions to be met. One of them is the prohibition of combining Estonian CIT with the privileges resulting from the decision on support within the Polish Investment Zone (PSI). The latest…
Estonian CIT and the employment condition – tax authorities versus the Supreme Administrative Court
Several weeks ago, this blog provided commentary on the Supreme Administrative Court ruling of 15 May 2025 (ref.). II FSK 163/25 [1] provided a clear definition of the interpretation of the employment condition in Estonian CIT. The Supreme Administrative Court ruled that the requirement of 300 days of employment per year should be applied to…
Practical significance of the explanations of 3 July 2025 concerning WHT in relation to the LTA concept
The tax explanations concerning the application of the beneficial owner (BO) clause significantly clarify and, we hope, will facilitate the application of the look-through approach (LTA). The application of the LTA may prove crucial for international capital groups where WHT-taxable receivables are transferred in a payment chain between several related entities. What is the LTA…
TPR Profitability – analysis, challenges and finalisation of data for transfer pricing purposes
TPR (Transfer Pricing Report) is a key obligation for taxpayers carrying out transactions with related entities. Its purpose is to provide the tax authorities with essential information about transactions, including the reported profitability. TPR reporting is not merely a formality – it is a tool that enables quick insight into transactions and facilitates the selection…
Climate justice in Hague. Has the UN Court opened the path to reparations?
On 23 July 2025, the International Court of Justice (ICJ) issued an advisory opinion concerning the obligations of states with regard to climate protection. This case originated from an initiative by students from the Pacific Island Students Fighting Climate Change, who demanded actions to protect islands threatened with extinction due to climate change. The initiative…